So, Why is there No Rural Email Completion Problem?

Just over a week ago, the FCC released an order intended to try and improve the rate at which long distance calls to rural areas are completed. That led to a somewhat cryptic tweet on which I now expand. (In today’s blog “email” is playing the role of Internet traffic in general.)

Have you heard the one about the five policy wonks who couldn’t agree on why there’s no rural email completion problem? The wireless guy challenged the premise of the question by arguing that it would only be an interesting question if the rural call completion problem actually existed. The ILEC guy said that of course there’s a rural email completion problem (that problem being that the ILEC is not getting paid to complete them). The Internet guy said that as long as there’s net neutrality, the end-to-end principle ensures that there can be no rural email completion problem. The right-wing think tank guy said that the free market prevents the emergence of a rural email completion problem. And the public interest guy said that even if there is no rural email completion problem, which he did not concede, the FCC should adopt rules to prohibit it. Ba dump bump!

But seriously folks, why is there no rural email completion problem? You’re probably expecting me to say that it’s because peering is unregulated, or because there’s no intercarrier compensation for email, or because email providers lack market power. And while all of those are true and important, I’d like to focus on a more fundamental distinction between the public switched telephone network (PSTN) and the Internet – the fact that there’s no such thing as “local Internet service.”

For a very long time (and to some extent even to this day), the voice world distinguished between “local exchange service” and “long distance service,” largely because they were regulatorily-driven constructs. The domain of the local service provider was required to end at some specific geographic point. It might be the exchange boundary, or maybe the LATA, or maybe even at a tandem switch. In any case, at that point responsibility for the transmission of a call, in either direction, passed from the local exchange carrier to the long distance carrier, or interexchange carrier (IXC). As a consequence of this distinction, long distance carriers became financially responsible for the transport path between rural exchanges and the rest of the PSTN.

The Internet never developed this distinction, either organically or through regulation. The service sold by every ISP to its customers is not defined as the ability to exchange packets with other users within some arbitrary geographic construct, but rather as the ability to exchange packets with every other Internet user anywhere in the world. In this model, every ISP voluntarily assumes the responsibility for establishing adequate transport between its network and the rest of the Internet, whether directly or, in most cases, indirectly. In the case of rural ISPs, they provision transport based on their customers’ needs into Internet exchange points – whether it be just one or many – where they then typically purchase competitive transit services to reach the rest of the Internet.

Thus, one important reason why there is no rural email completion problem is because, on the Internet, rural ISPs retain the responsibility for ensuring that their customers are connected to the rest of the Internet. In contrast, on the PSTN, responsibility for transmission of long distance calls to rural exchange customers is dispersed among a plethora of long distance carriers, or IXCs (wireless providers, VoIP providers, etc.), that may have varying degrees of concern about whether a tiny percentage of their calls destined for rural areas are successfully completed or not. Because the provider with the most direct customer relationship – and thus the most immediate concern for that customer’s service quality – retains the responsibility for connectivity to the Internet, the Internet approach of not distinguishing local from long distance has produced a better outcome for rural customers or, at the very least, the avoidance of an arcane debate over rural email completion. Either way, I think we can agree we’re better off.

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The local/long-distance distinction is mostly gone from a retail perspective, but it’s pervasive in interconnection and compensation. I would suggest that, as an industry, we should not import any of those distinctions into the model for end-to-end IP communications services. So, for example, any numbering database for IP end-points should not be based on rate centers, LATAs, etc.